S. 9(1)(vi) : Income deemed to accrue or arise in India- Royalty- Transfer of off-the-shelf- Software-Not assessable in India as royalty-DTAA-India- Israel. [S. 260A, Art. 12 (3)]

S. 45 : Capital gains – Interim order – Year of taxability of capital gains on compensation- Interest on compensation-Income from other sources – Delay of 404 days – Delay is condoned – The compensation and interest received by in pursuance of an interim order of the Bombay High Court cannot be taxed in the year of receipt – Addition is deleted – Compensation and interest can be taxed only when the final order is passed by the High Court . [ S. 45(5)(b) , 45(5)( c) ,56(2)(viii) Land Acquisition Act , 1894, S. 11, 18 ]

S. 272A : Penalty – Failure to answer questions – Sign statements – Furnish information – No notice were received – Sufficient and reasonable cause for non-attendance – Without providing sufficient time to reply cannot be treated as non-compliance u/s.272A(1)(d) -Penalty is deleted . [ S. 272A(1)(d) ]

S. 272A : Penalty – Failure to answer questions – Sign statements – Furnish information -The penalty cannot be imposed when AO expresses satisfaction with the assessee’s compliance.[ S. 272A(1)(d) ]

S. 271AAB:Peanlty -Search initiated on or after Ist day of July 2012-Assessment completed u/s. 143(3) – Addition made – Reopening u/s. 147 – Again additions made – Two penalty proceedings for both addition – Merging of penalty is not valid – Not specifying the charge – Barred by limitation- Penalty order is quashed . [ S. 274 ,275 ] .

S. 271(1)(c) : Penalty – Concealment – No specific limb in penalty notice – Penalty order is set aside.[ S. 274 ]

S. 271(1)(c) : Penalty – Concealment -Depreciation- The Charitable trust voluntarily withdrew the depreciation claim, and there is no deliberate concealment or misrepresentation, penalty- Penalty is deleted .[ S. 11, 32 ]

S. 263 : Commissioner – Revision of orders prejudicial to revenue –
Income from other sources – Purchase of immoveable property – difference in actual sale price and the stamp duty value – Addition of total stamp duty value- Matter remanded to CIT for further verification. [ S. 56(2)(x) , 69A ]

S. 263 : Commissioner – Revision of orders prejudicial to revenue –
Income from other sources – Interest -Zero coupon debentures redeemable after 9 years to its directors – Premature converted in to equity – Interest amount deemed to be received upon conversion of debentures in to equity shares in relevant assessment year – Revision order is justified . [ S. 2(24)(iv) 47(x),47(x)(a), 49(2A), 56(2),(id), 145 ]

S. 263 : Commissioner – Revision of orders prejudicial to revenue – Disallowance of expenditure – Exempt income – Outstanding GST – Revision order is affirmed – Registration and provision for warranty – Revision is not justified . [ S. 14A ,37(1) 43B ]